Purpose of this notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This privacy notice does not cover any links to external sources contained within our website or documents. We encourage you to read the privacy notices on any other websites you visit.
About us
Godfrey Wilson Limited (“Godfrey Wilson”, “we”, “us”, “our” and “ours”) is firm of auditors, accountants and consultants. We are registered as a private limited company in England and Wales under number 04537489 and our registered office is 5th Floor, Mariner House, 62 Prince Street, Bristol, BS1 4QD.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Lead. Our Data Protection Lead is Alison Godfrey. Alison can be contacted at alison@godfreywilson.co.uk or 0117 971 3445.
How we collect your personal data
We obtain personal data about you, for example, when:
- You visit our website (for example to help our website run more effectively)
- You contact us by email, telephone, post or social media (for example when you have a query about our services)
- You request a proposal from us in respect of the services we provide
- You engage us to provide our services and also during the provision of those services
- You supply goods or services to us
- You apply for a job with us
Most of our work is with organisations such as companies or charities. In carrying out our work we may process personal data belonging to an employee, subcontractor, supplier, member, donor or customer of a client, for example:
- When a client engages us to provide our services and also during the provision of those services
- From third parties and/or publicly available resources (for example from Companies House)
The kind of information that we hold about you
The information we hold about you may include the following:
- Your personal details (such as your name and/or address)
- IP address (this is to help us run our website efficiently)
- Details of contact we have had with you in relation to the provision, or the proposed provision, of our services
- Details of any services you have received from us
- Information provided as part of a job application
- Our correspondence and communications with you
- Information about any complaints and enquiries you make to us
- Information from feedback surveys and marketing activities that you chose to take part in
As part of our engaged work we may also hold information we receive from other sources, such as publicly available information or information provided by our client where you may be an employee, subcontractor, supplier, member, donor or customer.
How we use personal data we hold about you
We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier, member, donor or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, administrative and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- Carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services)
- Carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be an employee, subcontractor, supplier, member, donor or customer of our client
- Provide you with information related to our services that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes
- Seek your thoughts and opinions on the services we provide
- Notify you about any changes to our services
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Data retention
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- The requirements of our business and the services provided
- Any statutory or legal obligations
- The purposes for which we originally collected the personal data
- The lawful grounds on which we based our processing
- The types of personal data we have collected
- The amount and categories of your personal data
- Whether the purpose of the processing could reasonably be fulfilled by other means
Change of purpose
If we would like to use your personal data for any reason other than the reason for which we have collected it we will notify you, or where applicable we will ask for your consent.
Data sharing
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
We may use third party service providers who may process your personal data. The following activities are carried out by third-party service providers: IT and cloud services, website services, and professional advisory services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may also need to share your personal data with a regulator or to otherwise comply with the law.
Data security
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Rights of access, correction, erasure and restriction
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of the relevant changes.
By law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible
If you want to exercise any of the above rights, please get in touch with our Data Protection Lead.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent for direct marketing you can click unsubscribe on any direct marketing emails that you receive or please contact our Data Protection Lead.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to this notice
Any changes we may make to our privacy notice in the future will be updated on our website at: www.godfrey-wilson/privacy-policy/
This privacy notice was last updated in May 2018 and is consistent with the ICAEW privacy policy template dated April 2018.
Contact us
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please contact our Data Protection by email, or by post at:
Data Protection
Godfrey Wilson Limited
5th Floor, Mariner House
62 Prince Street
Bristol
BS1 4QD
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745